LEGAL

Acceptable Use Policy

COBBY PAY LTD.

Effective date: 7 October 2026

This Policy forms part of the terms governing use of CobbyPay Services. It is designed to support compliance with Canadian law, sanctions, AML/ATF requirements, fraud prevention obligations, payment-network rules and CobbyPay’s risk appetite.

1. General rule

You must use CobbyPay only for lawful purposes and for activity accurately disclosed during onboarding. You must not use the Services to conceal the origin, destination, ownership, control or purpose of funds or to circumvent legal, regulatory, sanctions, tax, compliance or payment-network restrictions.

2. Prohibited activities

  • Money laundering, terrorist financing, proliferation financing, sanctions evasion or dealing with prohibited persons or jurisdictions.
  • Fraud, scams, identity theft, deceptive practices, unauthorized transactions, account takeover or use of stolen financial information.
  • Ransomware, malware, darknet markets, illicit hacking services or proceeds of cybercrime.
  • Unlicensed or unlawfully offered financial, money transmission, investment, securities, gambling or virtual-asset services.
  • Shell banks or anonymous/fictitious accounts.
  • Human trafficking, exploitation, child sexual abuse material, illegal drugs, illegal weapons or other unlawful goods/services.
  • Transactions designed to evade reporting, verification, monitoring, limits or source-of-funds requirements.
  • Cryptocurrency mixers/tumblers or anonymity-enhancing services where prohibited by CobbyPay’s risk policy.
  • Any activity prohibited by applicable law, card/payment scheme rules, banking partners or CobbyPay’s published or communicated restrictions.

3. Restricted/high-risk activity

CobbyPay may require enhanced due diligence, impose limits, require prior approval, or decline activity involving high-risk jurisdictions, complex ownership structures, high-risk industries, unusual transaction patterns, digital assets, cash-intensive businesses, charities/non-profits, intermediaries, nested payment activity or other elevated-risk scenarios.

4. Monitoring and information requests

CobbyPay may monitor transactions and account activity and request invoices, contracts, proof of delivery, counterparty information, source of funds/source of wealth evidence, wallet information or other supporting material. Failure to provide satisfactory information may result in delay, rejection, restriction or termination.

5. Enforcement

CobbyPay may refuse or return transactions where possible, restrict functionality, suspend or close accounts, retain records, and make reports or disclosures to competent authorities where required or permitted by law. CobbyPay may be legally restricted from explaining certain actions.

6. Changes

CobbyPay may amend this Policy as laws, sanctions, payment-network requirements, products and risk controls change.